Great American Insurance Company v. Revolutionary Productions Inc. a/k/a Sum of Us Festival

CourtDistrict Court, E.D. California
DecidedMay 13, 2026
Docket1:24-cv-01001
StatusUnknown

This text of Great American Insurance Company v. Revolutionary Productions Inc. a/k/a Sum of Us Festival (Great American Insurance Company v. Revolutionary Productions Inc. a/k/a Sum of Us Festival) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Great American Insurance Company v. Revolutionary Productions Inc. a/k/a Sum of Us Festival, (E.D. Cal. 2026).

Opinion

4 UNITED STATES DISTRICT COURT 5 6 EASTERN DISTRICT OF CALIFORNIA 7 GREAT AMERICAN INSURANCE Case No. 1:24-cv-01001-JLT-SAB 8 COMPANY, FINDINGS AND RECOMMENDATIONS 9 Plaintiff, RECOMMENDING GRANTING PLAINTIFF’S MOTION FOR DEFAULT 10 v. JUDGMENT

11 ORDER REQUIRING SERVICE ON REVOLUTIONARY PRODUCTIONS INC. DEFENDANT WITHIN THREE DAYS a/k/a Sum of Us Festival, 12 (ECF No. 37) 13 Defendant. OBJECTIONS DUE WITHIN FOURTEEN 14 DAYS 15 Pending before the Court is Plaintiff Great American Insurance Company’s (“Plaintiff”) 16 motion for default judgment. Plaintiff seeks default judgment against Defendant Revolutionary 17 Productions Inc. (“Defendant”). No opposition to the motion was filed. On May 13, 2026, the 18 Court held a hearing on the motion, at which no appearance was made on behalf of Defendant. 19 Having considered the moving papers, the declarations and exhibits attached thereto, 20 Defendant’s nonappearance, as well as the Court’s file, the Court issues the following findings 21 and recommendations recommending granting Plaintiff’s motion for default judgment. 22 II. 23 RELEVANT BACKGROUND 24 A. The Underlying Prelitigation Claim 25 Plaintiff filed this action for declaratory judgment under 28 U.S.C. § 2201(a) to be 26 relieved of any duty to defend or indemnify Defendant under an insurance policy for injuries 27 sustained by third party Natalie Noghrey (“Noghrey”) while attending the Sum of Us Festival 28 1 2023 (the “Festival”). (ECF No. 30 (“FAC”), ¶¶ 1-2.) This action arises from Noghrey’s 2 complaint against Sum of Us in Natalie Noghrey v. Revolutionary Productions, Inc. aka Sum of 3 Us Festival, et al., County of San Francisco Superior Court Case No. CGC-25-629071. (FAC 4 ¶ 28; Ex. E.) 5 According to Plaintiff’s complaint, Noghrey was drinking alcohol on the evening of 6 September 15, 2023 while attending the Festival. (Id. ¶ 20.) The Festival furnished some of the 7 alcohol Noghrey consumed. (Id. at ¶ 26.) Plaintiff provides three receipts for alcohol purchases 8 allegedly made by Noghrey between 8:22 p.m. and 11:46 p.m., each identifying Defendant as 9 the retailer. (Id. at ¶ 27; Ex. D.) Plaintiff alleges the liquor license for the event was 10 nontransferable and issued to the Social Influence Foundation. (FAC ¶ 26.) The bartenders on 11 the night of the incident entered into separate written Volunteer Agreements for the Festival 12 with Defendant whereby they agreed to provide services in exchange for free or discounted 13 entry into the Festival. (Id. at ¶¶ 26, 27; Ex. C.) Plaintiff alleges that Defendant paid the 14 bartenders their bartending tips from the Festival. (FAC ¶ 27.) 15 As the evening progressed, Festival organizers and staff determined that Noghrey was 16 excessively intoxicated and that she needed to be taken back to her campsite. (FAC ¶ 23.) 17 When Festival organizer, Nadia Eker, and employee, Iris Triska, attempted to walk Noghrey in 18 the direction of her campsite, Eker and Triska identified a golf cart being driven by employee, 19 Jess Weiner. (Id.) Weiner was transporting another attendee to the medical area. (Id.) Eker 20 and Triska asked Weiner if they could ride on the golf cart to either reach the command center, 21 the medical area, or get as close as possible to Noghrey’s cabin. (Id.) 22 Between approximately 1:20 a.m. and 2:00 a.m. on September 16, 2023, Weiner made a 23 right turn and Noghrey allegedly fell out of the golf cart and hit her head on the pavement, 24 rendering her unconscious. (FAC ¶¶ 20, 24.) Noghrey’s claim alleges that she was rushed to 25 the hospital where she stayed under 24-hour care for nearly a month before she was discharged. 26 (Id. at ¶ 24.) Noghrey claims she has sustained permanent injuries as a result of the incident. 27 (Id.) 28 Noghrey claims that Defendant owed Noghrey a heightened duty standard of care 1 because of her intoxicated state. (FAC ¶ 25.) Noghrey further claims Defendant breached its 2 heightened duty because Defendant’s employees failed to ensure Noghrey’s safety after they 3 placed her in the golf cart. (Id.) 4 B. Terms of the Policy 5 Plaintiff issued a policy number 472-50-34-01 to named insured Sports and Recreation 6 Providers Association for the policy period February 2, 2023 to February 2, 2025 (the “Master 7 Policy”). (FAC at ¶ 9; Ex. A (“Policy Common Declarations”) at 1.) Under the Certificate of 8 Coverage No. GAS114226 Form 36270 (Ed. 05/18) in connection with the Master Policy (the 9 “Certificate”), Defendant Revolutionary Productions, Inc.: Sum of Us Festival “qualifies as an 10 insured under the Master Policy for the period of September 11, 2023 to September 19, 2023.”1 11 (FAC ¶ 10; Ex. B.) The Certificate provides insurance subject to all its terms, conditions, and 12 limitations and incorporates the Master Policy by reference. (Id.) The Certificate provides that 13 “[c]overage only applies to ‘Certificate Holders’ [i.e., Revolutionary Productions, Inc.: Sum of 14 Us Festival] for whom coverage has been placed in this program and by whom the premiums 15 have been paid. Coverage does not apply to the ‘Policyholder’ [i.e., Sports and Recreation 16 Providers Association].” (FAC, Ex. B (“Certificate of Coverage”) at 3.) Coverage by the 17 insurance policy was limited to injury or damage caused by and occurring at the Sum of Us 18 Festival. (FAC, Ex. B (“Limitation of Coverage to Designated Operations or Locations”) at 1.) 19 The Certificate affords (1) commercial general liability coverage with limits of insurance 20 of $1,000,000 each “occurrence”2 and in the aggregate, and (2) professional liability coverage 21 with limits of insurance of $1,000,000 each act, error, or omission and in the aggregate. (FAC, 22 Ex. B (“Certificate of Coverage”) at 1-2.) Notably, the Certificate indicates “liquor liability” 23 and “hired and non-owned autos” are “Not Covered.” (Id.) 24 / / /

25 1 Both the Master Policy and the Certificate are attached to the complaint and form the basis of Plaintiff’s claims. (FAC, Exs. A, B.) The Court finds both are incorporated by reference and may be considered. See Coto Settlement 26 v. Eisenberg, 593 F.3d 1031, 1038 (9th Cir. 2010); see also Fed. R. Civ. P. 10(c). 2 The Master Policy defines “occurrence” as “an accident, including continuous or repeated exposure to 27 substantially the same general harmful conditions.” (FAC, Ex. A (“Commercial General Liability Coverage Form”) at 18.) 28 1 1. Commercial General Liability Coverage 2 The Master Policy provides commercial general liability coverage pursuant to Form CG 3 00 01 (Ed. 04/13). (FAC ¶ 12.) The Master Policy provides, in pertinent part, the following 4 coverage by Plaintiff for bodily injury and property damage liability: 5 a. We will pay those sums that the Insured becomes legally obligated to pay as damages because of “bodily injury”3 or 6 “property damage” to which this insurance applies. We will 7 have the right and duty to defend the Insured against any “suit”4 seeking those damages. However, we will have no duty to 8 defend the Insured against any "suit" seeking damages for "bodily injury" or "property damage" to which this insurance 9 does not apply. We may, at our discretion, investigate any “occurrence” and settle any claim or “suit” that may result… 10

11 b. This insurance applies to “bodily injury” and “property damage” only if: 12 (1) the “bodily injury” or “property damage” is caused by an 13 “occurrence” that takes place in the “coverage territory”;

14 (2) the “bodily injury” or “property damage” occurs during the 15 policy period… 16 (Id.; Ex.

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Great American Insurance Company v. Revolutionary Productions Inc. a/k/a Sum of Us Festival, Counsel Stack Legal Research, https://law.counselstack.com/opinion/great-american-insurance-company-v-revolutionary-productions-inc-aka-caed-2026.